What You Fail to Say in a Financial Promotion Is Just as Regulated as What You Do Say

Italy’s competition authority, the AGCM, fined Revolut €11.5 million for misleading commercial practices. The core of the finding was not that Revolut lied. It was that Revolut’s promotions created impressions (about fees, features, and account terms) that the small print did not adequately correct. The gap between what consumers understood and what they were actually signing up for was wide enough for a regulator to drive a substantial fine through.

This is not a uniquely Italian story. It is a story about how financial promotions work, and how they fail.

The Omission Problem

Financial promotions law in the UK, as in most comparable jurisdictions, covers not just false statements but misleading omissions. A promotion that says something technically true but leaves out the information a consumer needs to understand what they are actually being offered is not compliant. It is misleading by omission.

This is a harder discipline than it sounds. Marketing teams are trained to highlight the attractive features of a product: the zero fees, the market-rate exchange, the instant access. They are not trained to give equal prominence to the conditions that attach to those features, the circumstances under which they do not apply, or the costs that emerge when the headline terms expire or change.

The result, in many financial services firms, is a structural tension. The marketing function is optimising for conversion. The compliance function is optimising for accuracy. And the gap between those two objectives is where regulatory risk lives.

The “First Point of Contact” Standard

UK financial promotions rules include a concept that the Revolut case illustrates well: the idea that the first point of contact between a firm and a potential customer carries particular weight.

The FCA has long emphasised that promotions must be clear, fair and not misleading not just in their technical accuracy but in the impression they create. A consumer who sees a social media ad and forms a reasonable but incorrect understanding of what a product costs has been misled, even if the correct information was available somewhere on the website, in smaller text, on a different page.

The “first point of contact” standard means that firms cannot rely on subsequent disclosure to correct an initial impression. If the promotion creates the wrong impression, later clarification is too late. The damage is done.

For firms operating at scale across digital channels (social media, paid search, in-app notifications, influencer partnerships) this standard is demanding. Every touchpoint is a potential “first point of contact.” Every piece of content that could reach a new consumer is, in principle, a financial promotion.

The Balance That Should Not Feel Impossible

There is a version of the Revolut story that is simply a story about a firm moving a bit too fast in a market it did not fully understand. But there is a more useful version, which is a story about a structural problem that affects the whole industry.

The structural problem is this: financial promotions compliance, done well, requires rapid review against a complex and evolving rulebook, across multiple formats and channels, with a full audit trail. Done badly (or not done at all) it generates exactly the kind of omissions that the AGCM found in Revolut’s Italian campaigns.

Compliance teams at regulated firms know this. They also know that the manual processes most firms use to manage promotions review do not scale to the volume and velocity that modern financial services marketing demands. The choice between speed and compliance should not be a choice at all. It is a structural failure that firms have learned to treat as normal.

The Revolut fine is a reminder of what that trade-off actually costs when it goes wrong. Not just the headline number - although €11.5 million is notable - but the reputational damage, the regulatory scrutiny, and the signal it sends to other regulators across other markets that a firm’s compliance infrastructure is not keeping pace with its growth.

Getting promotions compliance right, at speed and at scale, is not a luxury for fast-moving firms. It is the table stake.

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Karavel was built to close the gap between marketing speed and compliance rigour. If you would like to understand how we help financial services firms review promotions faster without compromising accuracy, get in touch.